Thomas W. Roberts - Page 14




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          less, sec. 6673(a)(1)(B).                                                    
               In Pierson v. Commissioner, 115 T.C. 576, 581 (2000), we                
          issued an unequivocal warning to taxpayers concerning the imposi-            
          tion of a penalty under section 6673(a) on those taxpayers who               
          abuse the protections afforded by sections 6320 and 6330 by                  
          instituting or maintaining actions under those sections primarily            
          for delay or by taking frivolous or groundless positions in such             
          actions.  In the petition and in petitioner’s motion and his                 
          response to respondent’s motion, petitioner is raising, we                   
          believe primarily for delay, arguments and contentions that we               
          have previously rejected, thereby causing the Court to waste its             
          limited resources.12  We shall impose a penalty on petitioner                
          pursuant to section 6673(a)(1) in the amount of $10,000.                     
               We have considered all of the arguments and contentions that            
          petitioner advances in petitioner’s motion and petitioner’s                  
          response to respondent’s motion, which are not discussed herein,             
          and we find them to be without merit and/or irrelevant.                      
               On the record before us, we shall deny petitioner’s motion,             
          and we shall grant respondent’s motion.                                      





               12Petitioner is well aware of the Court’s views regarding               
          the allegations of error that he raised in the petition.  They               
          are essentially the same allegations that he raised as the                   
          representative for the taxpayer in Davis v. Commissioner, supra,             
          and for the taxpayer in Wylie v. Commissioner, supra.                        





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